Moore Doeren Mayhew Blog

ARE YOU REQUIRED TO FILE A FATCA CERTIFICATION?

A FATCA certification consists of one or more series of questions that the Responsible Officers (RO) of certain Foreign Financial Institutions (FFIs) must answer and submit to the IRS to confirm the entities’ compliance with the requirements of FATCA. There are two general types of certifications:

one that relates to an entity’s preexisting accounts (COPA) and

another that relates to the entity’s compliance with various FATCA requirements (periodic certification).

Normally FFIs must file the periodic certification by July 1. If you have a Global Intermediary Information Number (GIIN), it is very possible you must file the periodic certification.

FFIs in Model 1 IGA countries are not required to file the certification provided they are not a participating FFI of an electing consolidated compliance group. FFIs in Model 2 IGA countries and participating FFIs in countries that do not have an IGA with the US would be required to file the certification. Also included would be Sponsoring Entities of Sponsored FFIs and Trustees of Trustee Documented Trusts.

Note: The registration system (on which you should have registered to obtain your GIIN) will suggest the certification(s) for an entity based on its FATCA classification in question four of the registration system. Therefore, even entities that do not have a certification requirement should update their FATCA classification to avoid inapplicable certification-related notices in the future.

FATCA Certifications Due July 1, 2020 Extended to December 15, 2020

In response to disruptions related to the COVID-19 virus, the IRS will grant an automatic extension of time to an entity with a FATCA certification due date of July 1, 2020 to submit a FATCA certification. FATCA certifications that are due on July 1, 2020 will be automatically extended to December 15, 2020 within the FATCA registration system.

The following is the FAQ from the IRS FATCA website that provided for the extension of time:

Yes. In response to disruptions related to the COVID-19 virus, the IRS will grant an automatic extension of time to submit a FATCA certification for an entity with a certification due date of July 1, 2020. FATCA certifications that are due on July 1, 2020 will be extended to December 15, 2020, without the need to file an extension request with the IRS. The new due date will automatically show on the FATCA registration system.

Moore Doeren Mayhew offers a full complement of FATCA/CRS services, including classification of entities; procedures, policy and documentation requirements; compliance and reporting assistance; training and awareness workshops; and, individual taxpayer consultation. Please contact us when we can be of assistance to you.

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